https://www.taxtmi.com/caselaws?id=752441 ITAT Ahmedabad decided against the assessee on provident fund disallowance under section 43B, following SC precedent in Checkmate Services case. For section 35D disallowance, matter was remanded to CIT(A) for proper adjudication as alternative plea wasn't considered. Regarding transfer pricing adjustment, ITAT found TPO and CIT(A) failed to properly evaluate assessee's manufacturing activities and export nature (98% export unit). TPO incorrectly rejected CUP method despite accepting it for similar transactions in previous years. Matter remanded to TPO for fresh adjudication considering appropriate method and risk factors. Appeal partly allowed for statistical purposes. en-us Wed, 08 May 2024 00:00:00 +0530 Thu, 09 May 2024 17:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752441 ITAT Ahmedabad decided against the assessee on provident fund disallowance under section 43B, following SC precedent in Checkmate Services case. For section 35D disallowance, matter was remanded to CIT(A) for proper adjudication as alternative plea wasn't considered. Regarding transfer pricing adjustment, ITAT found TPO and CIT(A) failed to properly evaluate assessee's manufacturing activities and export nature (98% export unit). TPO incorrectly rejected CUP method despite accepting it for similar transactions in previous years. Matter remanded to TPO for fresh adjudication considering appropriate method and risk factors. Appeal partly allowed for statistical purposes. Case-Laws Income Tax Wed, 08 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752441